### Revision to the



## New Hampshire State Implementation Plan

Maintenance Plan for

Former 1-Hour Ozone Nonattainment Areas in Cheshire, Hillsborough, Merrimack, Rockingham,

and Strafford Counties

March 2, 2012



## Air Resources DivisionThis page intentionally left blank.New Hampshire Ozone Maintenance SIP Page i

TABLE OF CONTENTS

1. INTRODUCTION..............................................................................

................... .1 1.1 Background............................................................................... ....................1

1.2 National Ozone Standards............................................................

............... .......1

1.3 Attainment Status........................................................................

.............. ......2

1.4 SIP Revisions..............................................................................

................. .6 1.5 Maintenance Plan Components.........................................................

.................... 7

2. ATTAINMENT INVENTORY AND MAINTENANCE DEMONSTRATI ON............... ...........8 2.1 2002 Attainment Inventory...............................................................

...... ............8 2.2 2012 and 2014 Projected Inventories........................

............... ............... ...............9

2.3 Maintenance Demonstration............................................................... ...............10

3. AMBIENT AIR QUALITY MONITORING...................................................... ...........13

4. CONTINGENCY PLAN.............................................................................. ...........14 4.1 ICI Boilers (at Major Point Sources).................................

.......... ....... ........... .......15
4.2 Emulsified Asphalt Paving......................................................

........ ........... ......15

4.3 Consumer Products...................................................

............ ....... ............ .......15

4.4 Additional Controls on Boilers................................................

............ ...............16 4.5 Other Contingency Measures...................................................

.......... ...... .........17

5. VERIFICATION OF CONTINUED ATTAINMENT....................................

... ........... ....18

6. ADMINISTRATIVE DOCUMENTS...................................................

.............. .........18

7. SUMMARY....................................................................................

.............. .....18

LIST OF FIGURES

Figure 1-1 New Hampshire 1-hour and 8-hour Nonattai nment Areas...............

......... .................5

LIST OF TABLES

Table 1-1 New Hampshire Designations/Classification s for 1-Hour Ozone Standard

Revised as of July 1, 2002 (40 CFR 81.330) ........................

.................. ................3
Table 1-2 New Hampshire Designations/Classificatio ns for the 1997 8-Hour Ozone Standard

Effective June 15, 2004 (FR 69 23857) ..................

........................ ............. .........4

Table 1-3 1-Hour Ozone Nonattainment/Maintenance Ar eas Designated Unclassifiable/

Attainment for the 1997 8-Hour Standard as of June 15, 2004............

...... .................7

Table 2-1 2002 vs. 2012 and 2014 NOx and VOC Emissi ons for Cheshire, Hillsborough,

Merrimack, Rockingham, and Strafford Counties..................

......... ............... ......10
Table 3-1 8-Hour Ozone Monitoring Data: 2012 Thresh old Values and 2010-2011 Design

Values Based on Fourth-Highest Annual Maxima..................... ...........................12

Table 4-1 Estimated Emission Reductions from Three BOTW Control Measures............ ............14
Table 4-2 Potential Contingency Measures for Reduci ng Ozone Levels........................ ...........16

LIST OF ATTACHMENTS

Attachment A 2002 Attainment Inventory and 2012 and 2014 Projected Inventories

Attachment B Administrative DocumentsNew Hampshire Ozone Maintenance SIP Page ii

This page intentionally left blank.New Hampshire Ozone Maintenance SIP Page 1

1. INTRODUCTION

This maintenance plan, presented as a revision to N ew Hampshire’s State Implementation Plan (SIP), addresses the anti-backsliding provisions of the Clean Air Act, Section 110(a)(1), with respect to the former 1-hour ozone standard after p romulgation of the 1997 8-hour ozone standard. The maintenance plan (also known as “maintenance SI P”) applies to former 1-hour ozone nonattainment areas constituting all of Cheshire Co unty and portions of Hillsborough, Merrimack, Rockingham, and Strafford Counties.

1.1 Background

Under Section 110(a)(1), states are required to imp lement, maintain, and enforce national primary ambient air quality standards:

“Each State shall, after reasonable notice and publ ic hearings, adopt and submit to the Administrator, within 3 years (or such shorter period as the Administrator may pr escribe) after the promulgation of a national prima ry ambient air quality standard (or any revision thereof) under se ction 109 for any air pollutant, a plan which provi des for implementation, maintenance, and enforcement of suc h primary standard in each air quality control regi on (or portion thereof) within such State...”

States are expected to meet these requirements thro ugh individualized State Implementation Plans. SIPs are dynamic documents describing the state’s s tatutory and regulatory (i.e., enforceable) emission control measures that will be implemented to ensure compliance with the national standards. SIPs must be periodically reviewed and updated to meet administrative requirements, changing air quality conditions, changing emissions , and new or amended federal programs.

1.2 National Ozone Standards

Since the 1970s, EPA has established and periodical ly reviewed/revised the national ambient air quality standards (NAAQS) for ground-level ozone. The original 1-hour primary standard of 0.08 parts per million (ppm) for photochemical oxidants, promulgated by EPA in 1971 ( Federal Register , 36 FR 8186), was revised in 1979 to a 1-hour stan dard of 0.12 ppm for ozone (44 FR 8202). In 1993, after a lengthy period of scientif ic review, litigation, and public input, EPA decide d to retain the 0.12 ppm standard (58 FR 13008). (No te: The secondary ozone standard was set identical to the primary standard.)

On July 18, 1997, EPA published a final rule for a new 8-hour ozone standard of 0.08 ppm to replace the 1-hour standard (62 FR 38855), effectiv e on September 16, 1997. This change was based on further scientific study concluding that t he 1-hour standard did not provide adequate health protection against extended periods of moderately e levated ozone levels. The 1997 8-hour ozone NAAQS bore a more direct relationship to ozone conc entrations associated with health effects.

As part of the transition to the more protective 8- hour standard, the agency issued rules determining that the 1-hour standard no longer applied in certa in areas. EPA subsequently rescinded this action in response to litigation that created uncertainty as to when and whether the 8-hour standard would be fully implemented. A rule reinstating the 1-hou r standard was published on July 20, 2000, and implementation of the newer standard was delayed fo r several years pending resolution of the legal issues. The Phase 1 implementation rule for the 8- hour ozone standard was published in final form on April 30, 2004 (69 FR 23857). On June 15, 2005, EPA revoked the 1-hour ozone standard for most areas of the country (including all of New Ham pshire) and replaced it with the 8-hour ozone standard (69 FR 23857 and 70 FR 44470).New Hampshire Ozone Maintenance SIP Page 2

In 2008, EPA further strengthened the 8-hour NAAQS for ground-level ozone to 0.075 ppm, effective on May 27, 2008 (73 FR 16435). After rec onsideration of the scientific evidence, on January 6, 2010, EPA proposed to reduce the standar d to 0.060-0.070 ppm (75 FR 2938). In its final determination, however, headquarters clarifie d that “EPA fully intends to implement this current standard [0.075 ppm] as required under the Clean Air Act,” (memo from Gina McCarthy, Assistant Administrator, to the Regional Air Divisi on Directors, September 22, 2011). While this provides historical context, the 2008 revision of t he ozone NAAQS is irrelevant to the antibacksliding provisions that serve as the reason for this maintenance plan. This plan is therefore unaffected by EPA’s most recent actions to strength en the 8-hour ozone standard.

1.3 Attainment Status

The 1990 amendments to the Clean Air Act establishe d an area classification system for attainment of the 1-hour ozone NAAQS. Under this system, all areas of the United States were designated as attainment, nonattainment, or unclassifiable, depen ding on the available monitoring data for those areas. In addition, attainment areas could be eith er classified or unclassifiable according to the adequacy of the monitoring data.

Nonattainment areas were further classified as marg inal, moderate, serious, severe, or extreme, to represent progressive levels of exceedance of the 1 -hour ozone standard. The 1990 amendments also established mandatory SIP submission requireme nts based on the ozone nonattainment designation.

New Hampshire’s area designations and classificatio ns for the 1-hour ozone standard are codified at 40 CFR 81.330 (Table 1-1). Counties in the norther n and central parts of the state were designated

as unclassifiable/attainment areas for 1-hour ozone . The more populous southeastern counties of Strafford, Rockingham, and Hillsborough, were desig nated as serious nonattainment areas. Southcentrally located Merrimack County was classified a s a marginal nonattainment area. Cheshire County, in the state’s rural southwest corner, was designated as a nonattainment area on the basis of incomplete data.

With the 1-hour area classifications already reinst ated, on July 24, 2000, NHDES submitted to EPA

its attainment classification recommendations for t he newer, 8-hour standard. This submittal was followed by another, on July 15, 2003, that include d consideration of Consolidated Metropolitan Statistical Area (CMSA) boundaries and other region al considerations in making recommendations for determining nonattainment areas for 8-hour ozon e.

Final attainment classifications for the 8-hour ozo ne standard appeared in the Federal Register on April 30, 2004 (69 FR 23857), with an effective dat e of June 15, 2004. EPA designated the New Hampshire portion of the Boston-Manchester-Portsmou th area as a moderate nonattainment area for the 8-hour ozone NAAQS (Table 1-2) with a maximum a ttainment date of June 15, 2010. It is worth noting that no monitor in New Hampshire had a n 8-hour ozone design value equal to or greater than 0.092 ppm, a situation that normally w ould have put the nonattainment area in the marginal classification. However, NHDES agreed to the moderate classification to provide regional consistency with contiguous nonattainment areas ext ending from southern Maine to Massachusetts.New Hampshire Ozone Maintenance SIP Page 3

Table 1-1. New Hampshire Designations/Classifica tions for 1-Hour Ozone Standard

Revised as of July 1, 2002 (40 CFR 81.330)

Area County Cities and Towns Included Designation/

Classification

Nonattainment Areas

Merrimack (all) Allenstown, Andover, Boscawen, Bow, Bradford,

Canterbury, Chichester, Concord, Danbury, Dunbarton, Epsom, Franklin, Henniker, Hill, Hooksett, Hopkinton, Loudon, New London, Newbury, Northfield, Tilton, Pembroke, Pittsfield, Salisbury, Sutton, Warner, Webster, Wilmot Nonattainment** / Marginal**

Hillsborough (part) Antrim, Bedford, Bennington, De ering, Francestown,

Goffstown, Greenfield, Greenville, Hancock, Hillsborough, Lyndeborough, Manchester, Mason, New Boston, New Ipswich, Peterborough, Sharon, Temple, Weare, Windsor Nonattainment** / Marginal** Manchester Area

Rockingham (part) Auburn, Candia, Chester, Deerfiel d, Epping, Fremont, Northwood, Nottingham, Raymond Nonattainment** / Marginal**

Hillsborough (part) Pelham, Amherst, Brookline, Hol lis, Hudson,

Litchfield, Merrimack, Milford, Mont Vernon, Nashua, Wilton. Nonattainment*/

Serious**Boston-LawrenceWorcester Area

Rockingham (part) Atkinson, Brentwood, Danville, Derry, East Kingston

, Hampstead, Hampton Falls, Kensington, Kingston, Londonderry, Newton, Plaistow, Salem, Sandown, Seabrook, South Hampton, Windham Nonattainment**/

Serious**

Rockingham (part)

Exeter, Greenland, Hampton, New Castle, Newfields, Newington, Newmarket, North Hampton, Portsmouth, Rye, Stratham Nonattainment**/

Serious**Portsmouth-DoverRochester Area

Strafford (all) Barrington, Dover, Durham, Farming ton, Lee, Madbury, Middleton, Milton, New Durham, Rochester, Rollinsford, Somersworth, Strafford Nonattainment**/

Serious**

Cheshire County Cheshire (all) Alstead, Chesterfiel d, Dublin, Fitzwilliam, Gilsum, Harrisville, Hinsdale, Jaffrey, Keene, Marlborough, Marlow, Nelson, Richmond, Rindge, Roxbury, Stoddard, Sullivan, Surry, Swanzey, Troy, Walpole, Westmoreland , Winchester Nonattainment**/ Incomplete

Data**

Unclassifiable/Attainment Areas

Belknap County Belknap all Unclassifiable/

Attainment

Sullivan County Sullivan all Unclassifiable/

Attainment

AQCR 107 Androscoggin Valley Interstate Coos all Unclassifiable/

Attainment

Carroll all Unclassifiable/

Attainment AQCR 149 Central New Hampshire Interstate

Grafton all Unclassifiable/

Attainment

* October 18, 2000 ** January 16, 2001New Hampshire Ozone Maintenance SIP Page 4

Table 1-2. New Hampshire Designations/Classificati ons for the 1997 8-Hour Ozone Standard Effective June 15, 2004 (FR 69 23857)

Area County Cities and Towns Included Designation/

Classification

Nonattainment Areas

Hillsborough (part) Amherst, Bedford, Brookline, Go ffstown, Hollis, Hudson,

Litchfield, Manchester, Merrimack, Milford, Nashua, Pelham Nonattainment Subpart 2/Moderate

Merrimack (part) Hooksett Nonattainment Subpart 2/Moderate

Rockingham (part) Atkinson, Auburn, Brentwood, Candia, Chester, Danvi lle,

Derry, E. Kingston, Epping, Exeter, Fremont, Greenl and, Hampstead, Hampton, Hampton Falls, Kensington, Kingston, Londonderry, New Castle, Newfields, Newington, Newmarket, Newton, North Hampton, Plaistow, Portsmouth, Raymond, Rye, Salem, Sandown, Seabrook, South Hampton, Stratham, Windham Nonattainment Subpart 2/ModerateBoston-ManchesterPortsmouth Area (Southeast New Hampshire Area)

Strafford (part) Dover, Durham, Rochester, Rollinsford, and Somerswo rth Nonattainment Subpart 2/Moderate

Unclassifiable/Attainment Areas

Hillsborough County Hillsborough (part) Antrim, Ben nington, Deering, Francestown, Greenfield, Greenville, Hancock, Hillsborough, Lyndeborough, Ma son, Mont Vernon, New Boston, New Ipswich, Peterborough, Sharon, Temple, Weare, Wilton, Windsor Unclassifiable/

Attainment

Merrimack County Merrimack (part) Allenstown, Ando ver, Boscawen, Bow, Bradford, Canterbury, Chichester, Concord, Danbury, Dunbarton

, Epsom, Franklin, Henniker, Hill, Hopkinton, Loudon, New London, Newbury, Northfield, Pembroke, Pittsfie ld, Salisbury, Sutton, Warner, Webster, Wilmot Unclassifiable/

Attainment

Rockingham County Rockingham (part) Deerfield, Nor thwood, Nottingham Unclassifiable/

Attainment

Strafford County Strafford (part) Barrington, Farmi ngton, Lee, Madbury, Middleton, Milton, New Durham, Strafford Unclassifiable/

Attainment

Belknap County Belknap all Unclassifiable/

Attainment

Carroll County Carroll all Unclassifiable/

Attainment

Cheshire County Cheshire all Unclassifiable/

Attainment

Coos County Coos all Unclassifiable/

Attainment

Grafton County Grafton all Unclassifiable/

Attainment

Sullivan County Sullivan all Unclassifiable/

Attainment

The nonattainment areas listed above for the 1-hour and 8-hour ozone standards are represented graphically in the map of Figure 1-1.

Note that these area classifications applied at spe cific dates during the first half of the previous decade. Because of regional progress in reducing e missions, some locations formerly identified as

nonattainment areas have since achieved attainment. Also, because of recent improvements in monitoring, some locations formerly designated as u nclassified attainment areas could now be redesignated as classified attainment areas. The classifications as listed here are relevant to this

maintenance SIP.New Hampshire Ozone Maintenance SIP Page 5

Figure 1-1. New Hampshire 1-hour and 8-hour Nonatt ainment AreasNew Hampshire Ozone Maintenance SIP Page 6

1.4 SIP Revisions

On June 30, 1998, NHDES submitted to EPA an ozone a ttainment demonstration for the New Hampshire portion of the Boston-Lawrence-Worcester 1-hour ozone serious nonattainment area. As required under the Clean Air Act, this SIP revis ion was a plan for achieving attainment of the 1-

hour ozone standard in the affected area. The fina l rule approving the attainment demonstration SIP was published on December 6, 2002 (67 FR 72574), an d became effective on January 6, 2003. The final rule set an attainment date of November 15, 2 007, and also approved the attainment-level vehicle emissions budgets for NOx and VOC for the N ew Hampshire portion of the BostonLawrence-Worcester serious nonattainment area for u se in meeting transportation conformity.

On December 30, 2004, NHDES submitted the required mid-course review for the New Hampshire portion of the Boston-Lawrence-Worcester 1-hour ozo ne serious nonattainment area. EPA gave notice, on October 12, 2005 (70 FR 59338), that New Hampshire had submitted an acceptable midcourse review and fulfilled its commitment made in the attainment demonstration plan.

On December 14, 2011, EPA published a proposed rule (76 FR 77739) determining that the BostonLawrence-Worcester MA-NH serious one-hour ozone non attainment area met the November 15, 2007, deadline for attaining the one-hour NAAQS for ozone, based on quality-assured, certified data for the 2005-2007 monitoring period.

When the attainment classifications for the 1997 8- hour ozone standard were issued in mid-2004, some locations in New Hampshire that were previousl y found to be in nonattainment for the 1-hour

ozone standard were determined to be in attainment for the 8-hour ozone standard. Although the 8- hour standard superseded the 1-hour standard, anti- backsliding provisions established at 40 CFR 51.905 required states to develop maintenance plans to prevent degradation of air quality in former

nonattainment areas that were reclassified to attai nment. In this instance, a maintenance plan was required for:

• Any attainment area or unclassifiable area for the 8-hour ozone standard that was formerly in nonattainment for the 1-hour ozone standard, or

• Any attainment area or unclassifiable area for the 8-hour ozone standard that was formerly

in nonattainment for the 1-hour ozone standard but that achieved attainment with an approved maintenance plan.

Table 1-3 lists the specific locations in New Hamps hire that meet these qualifications and are covered by this maintenance SIP. They include all, or port ions of, the following five southern New Hampshire counties: Cheshire, Hillsborough, Merrima ck, Rockingham, and Strafford (see the green-shaded area in the map of Figure 1-1).New Hampshire Ozone Maintenance SIP Page 7

Table 1-3. 1-Hour Ozone Nonattainment/Maintenance Areas Designated

Unclassifiable/Attainment for the 1997 8-Hour Stand ard as of June 15, 2004

(= Maintenance Planning Area) 1

Area County Cities and Towns Included

Boston-LawrenceWorcester Area Hillsborough (part) Mont Vernon, Wilton

Hillsborough (part) Antrim, Bennington, Deering, Fr ancestown, Greenfield, Greenville, Hancock, Hillsborough, Lyndeborough, Mason, New Bos ton, New Ipswich, Peterborough, Sharon, Temple, Weare, W indsor Manchester Area

Merrimack (part) Allenstown, Andover, Boscawen, Bow, Bradford, Cante rbury, Chichester, Concord, Danbury, Dunbarton, Epsom, Fra nklin, Henniker, Hill, Hopkinton, Loudon, New London, Newbury, North field, Pembroke, Pittsfield, Salisbury, Sutton, Warner, We bster, Wilmot

Rockingham County Rockingham (part) Deerfield, Northwood, Nottingham

Strafford County Strafford (part) Barrington, Farmington, Lee, Madbury, Middleton, Mi lton, New Durham, Strafford

Cheshire County Cheshire (all) Alstead, Chesterfield, Dublin, Fitzwilliam, Gilsum, Harrisville, Hinsdale, Jaffrey, Keene, Marlborough, Marlow, Nels on, Richmond, Rindge, Roxbury, Stoddard, Sullivan, Surry, Swanzey , Troy, Walpole, Westmoreland , Winchester

1.5 Maintenance Plan Components

The maintenance plan must be in the form of a SIP r evision providing for continued maintenance of the 8-hour ozone NAAQS in the planning area for 10 years from the effective date of the area’s designation as unclassifiable/attainment. The main tenance plan must contain, at a minimum, the following elements:

• an attainment inventory,

• a maintenance demonstration,

• provisions for continued ambient air quality monito ring,

• a contingency plan, and

• verification of continued attainment.

The required plan elements are addressed in the sec tions which follow.

1 Source: Table 2 of EPA’s “Maintenance Plan Guidan ce Document for Certain 8-hour Ozone Areas under Se ction 110(a)(1) of the Clean Air Act,” May 20, 2005.New Hampshire Ozone Maintenance SIP Page 8

2. ATTAINMENT INVENTORY AND MAINTENANCE DEMONSTRATI ON

The maintenance plan must demonstrate that the plan ning area will remain in compliance with the 8-hour ozone standard for the 10-year period follow ing the effective date of designation as

unclassifiable/attainment. To make this demonstrat ion, a state may use either an emissions inventory approach or other methods such as modelin g. New Hampshire is using the emissions inventory approach to demonstrate that future emiss ions of ozone precursors (NOx and VOC) will not exceed attainment inventory levels. Thus, the analysis requires development of a baseline attainment inventory as well as an inventory of fut ure emissions for the projection year, at a minimum. For areas (including New Hampshire) with an effective attainment designation date of June 15, 2004, for the 1997 8-hour ozone standard, the maintenance plan must project attainment for 2014. In addition, an emissions inventory was deve loped for an interim year (2012) to demonstrate that maintenance of the ozone standard is likely to continue throughout the 10-year period.

New Hampshire’s 2002 attainment inventory and proje cted 2012 and 2014 inventories presented in this section are divided into the following general emissions categories:

• Point Sources , which represent discrete facilities. These sourc es must usually meet certain emission thresholds to be included as point sources and therefore generally represent larger

facilities.

• Area Sources , which represent facilities and activities too num erous and widespread to be inventoried individually but which collectively may account for significant emissions.

• Non-Road Mobile Sources , including aircraft, locomotives, commercial marin e vessels, construction vehicles, lawn & garden equipment, and other mobile vehicles and equipment that are not meant to be operated on roadways.

• On-Road Mobile Sources , including cars, trucks, buses, motorcycles, and o ther vehicles that operate on public roadways.

To complete the inventories, NHDES followed EPA gui dance for making emission estimates of NOx and VOC on a typical summer day. The inventori es were prepared for the five southern New Hampshire counties of Cheshire, Hillsborough, Merri mack, Rockingham and Strafford. Note, however, that the maintenance planning area include s only parts of Hillsborough, Merrimack, Rockingham and Strafford Counties. It is sometimes difficult or impractical to apportion emissions to a resolution finer than the county level; and th e irregular geography of the maintenance planning area presented a particular challenge in this regar d. However, because the maintenance planning area constitutes a large geographic portion of the entire 5-county area, NHDES reasoned that

emission trends in the five southern counties would serve as an acceptable proxy for emissions trends in the maintenance planning area; the additi onal effort required to extract the estimates specific to the planning area would add little valu e to the analysis. Therefore, to the extent that t he inventory data show declining emissions in the 5-co unty area as a whole, the data also reflect improving air quality within the maintenance planni ng area.

2.1 2002 Attainment Inventory

The maintenance plan starts with a baseline attainm ent inventory of emissions, which details the volatile organic compounds (VOC) and oxide of nitro gen (NOx) emissions for the planning area on a “typical summer day.” The Phase 1 implementation rule for the 8-hour ozone standard specifies that the 10-year maintenance period begins on the e ffective date of the 8-hour ozone NAAQSNew Hampshire Ozone Maintenance SIP Page 9

designation. Although a state may use any of the t hree years upon which the 8-hour ozone designation was based (i.e., 2001, 2002 and 2003), EPA recommends that areas use 2002 as the attainment inventory base year. 2

NHDES previously prepared a 2002 Periodic Emissions Inventory for ozone precursors to satisfy New Hampshire’s obligations under the Consolidated Emissions Reporting Rule (CERR). NHDES formally submitted its 2002 Periodic Emissions Inve ntory to EPA on June 7, 2007 (cover letter to Robert Varney). For the purposes of this maintenan ce plan, New Hampshire is using that inventory as a basis for its 2002 attainment inventory for al l source categories.

Affected point-source facilities in New Hampshire a re required to report their emissions on an annual basis. The reporting requirements are speci fied under New Hampshire’s air regulations, air permitting program, and the CERR. The data submitt ed by these point-source facilities are extensively cross-checked and quality assured by NH DES staff before eventual submittal to EPA. Further details regarding New Hampshire point sourc e data collection and quality assurance programs are available in Section A, “Point Sources ,” of the documentation for New Hampshire’s 2002 Periodic Emissions Inventory.

The methodologies that New Hampshire used to prepar e its 2002 periodic area source emissions inventory came primarily from EPA’s Emissions Inven tory Improvement Program (EIIP). Methodologies for specific area source categories c an be found in EIIP Volume 3, Area Sources

, available at http://www.epa.gov/ttn/chief/eiip/tech report/volume03/index.html . Calculations for many area source categories are based on variables such as population, employment, and fuel consumption data. Detailed descriptions of the met hodologies used in the 2002 area source inventory can be found in Section B, “Area Source E missions,” of the documentation for New Hampshire’s 2002 Periodic Emissions Inventory.

For the non-road mobile category, New Hampshire use d the appropriate models for estimating nonroad vehicle emissions, including the Federal Aviat ion Agency’s (FAA’s) Emissions & Dispersion Modeling System (EDMS) for aircraft and airport gro und service equipment and EPA’s NONROAD model for other non-road equipment types. New Hampshire also used applicable references and methodologies for estimating emissio ns for those equipment types not included in

the EDMS and NONROAD models such as locomotives and CMVs. Detailed descriptions of the methodologies used by New Hampshire in its 2002 non -road mobile inventory can be found in the non-highway mobile sources portion of Section B, “A rea Source Emissions” of the documentation for New Hampshire’s 2002 Periodic Emissions Invento ry.

For on-road mobile sources, New Hampshire used vehi cle-miles-traveled (VMT) data obtained from the New Hampshire Department of Transportation and EPA’s MOVES motor vehicle

emission factors model.

2.2 2012 and 2014 Projected Inventories

In accordance with EPA guidance, NHDES prepared an estimate of ozone-precursor emissions projected to 10 years after June 15, 2004, the effe ctive date of the 8-hour ozone attainment designation. NHDES also prepared emission estimate s for the interim year 2012. For both projected inventories, NHDES used the Economic Grow th and Analysis System (EGAS) Version

2 EPA’s Consolidated Emissions Reporting Rule (CERR) already requires the development of a 2002 invento ry (40 CFR Part 51, Subpart A, 67 FR 39602, June 10, 2002)

.New Hampshire Ozone Maintenance SIP Page 10

5.0 to develop the applicable growth factors (excep t for NONROAD model sources and on-road mobile sources, as noted below). These growth fact ors were matched to the appropriate point, area, and mobile source categories using Source Classific ation Codes (SCC). With respect to area sources, New Hampshire has ado pted or is evaluating various control measures for a number of VOC source categories such as solve nt cleaning, architectural surface coating, etc. For those measures that are not yet SIP-approved, t he attendant emission reductions benefits are

omitted from the 2012 and 2014 inventories. As a c onsequence of this conservative approach, it is anticipated that the actual projected emissions in those years will be lower than the projected emissions presented herein.

Because analysis year is an inherent input into the NONROAD model, projected 2012 and 2014 non-road mobile emissions were estimated directly f or those non-road equipment categories that are

included in the model. For other non-road mobile c ategories such as aircraft, locomotives, and CMVs, the appropriate EGAS growth factors were used . For commercial aircraft and airport ground service equipment, the EGAS growth factors w ere applied to the specific activities (e.g., aircraft landing-takeoff operations); and the growt h-adjusted values were then input into the EDMS model. (Note: The EDMS model uses the analysis yea r to select the appropriate emission factors.)

For on-road mobile sources, future-year VMT data wa s derived using trends in historical VMT from the Federal Highway Administration (FHWA) and from the Metropolitan Planning Organizations (MPOs) that represent New Hampshire's ozone nonatta inment area. The transportation demand models used by the MPOs utilize population, employm ent, and other economic factors to growthadjust future-year VMT. Vehicle population data wa s adjusted for subsequent years using the growth factors from Table 3-14 of MOVES2010 Highway Vehicle Population and Activity Data, EPA-420-R-10-026, November 2010.

2.3 Maintenance Demonstration

Table 2-1 summarizes the 2002 attainment inventory and the projected 2012 and 2014 inventories for the five southern New Hampshire counties that e ncompass the Section 110(a)(1) maintenance planning area. As the inventory data show, total e missions of NOx and VOC are anticipated to decrease significantly through the period ending in 2014.

Table 2-1. 2002 vs. 2012 and 2014 NOx and VOC Emis sions for Cheshire, Hillsborough,

Merrimack, Rockingham, and Strafford Counties (poun ds per day)

NOx VOC Source Category 2002 2012 2014 2002 2012 2014
Point 67,347 48,358 50,739 15,898 6,696 7,005
Area 10,516 9,091 9,134 93,778 85,443 91,068
Non-Road Mobile 49,787 36,131 31,215 68,223 40,210 35,121
On-Road Mobile 261,303 75,202 62,347 87,161 36,904 34,245
Total 388,953 168,782 153,435 265,060 169,253 167,439

The figures shown above for the 2002 attainment inv entory differ somewhat from those previously submitted for the 2002 Periodic Emissions Inventory . The reasons for these differences are as

follows:New Hampshire Ozone Maintenance SIP Page 11

• The on-road mobile emissions estimates for the main tenance plan were calculated with MOVES, which was not available at the time that the 2002 Periodic Emissions Inventory was prepared. On-road mobile emissions estimates f or the 2002 Periodic Emissions Inventory were calculated using MOBILE6.2 emission factors.

• Similarly, emissions estimates for Stage II vapor r ecovery vehicle refueling (SCC 25-01- 060-100) for the maintenance plan were calculated w ith MOVES and were included and reported in the on-road mobile category. Stage II emissions estimates for the 2002 Periodic Emissions Inventory were calculated using MOBILE6.2 emission factors and were reported in the area source category. Since this category i s now calculated with MOVES and included under on-road mobile, the MOBILE6.2-based Stage II refueling emissions

estimates were removed from the area source invento ry. This resulted in an adjustment to the 2002 maintenance plan area source inventory of -2,638 pounds per day of VOC when compared with the previously submitted 2002 Periodi c Emissions Inventory.

• In compiling the 2002 figures for the maintenance p lan, it was discovered that emissions estimates for the industrial wood combustion catego ry (SCC 21-02-008-000) should not have been calculated and reported under the area so urce category. All industrial wood combustion in 2002 would have occurred at permitted point source facilities, and making an area source estimate for this category caused doubl e-counting. Therefore, the area source

estimate for industrial wood combustion was removed . This resulted in a correction to the 2002 maintenance plan area source inventory of -25, 357 and -880 pounds per day of NOx and VOC respectively when compared with the previou sly submitted 2002 Periodic Emissions Inventory.

The projected reductions in 2012 and 2014 are due t o the various federal and state programs to

control emissions from non-road and on-road mobile sources and to the gradual replacement over time of older, more polluting vehicles with newer, cleaner ones. Contributing to projected emission

reductions from the non-road mobile sector are the following federal programs:

• “Control of Air Pollution; Determination of Signif icance for Nonroad Sources and Emissions Standards for New Nonroad Compression Ign ition Engines at or above 37 Kilowatts,” 59 FR 31306, June 17, 1994.

• “Control of Emissions of Air Pollution from Nonroad Diesel Engines,” 63 FR 56967, October 23, 1998.

• “Control of Emissions from Nonroad Large Spark-Igni tion Engines and Recreational Engines (Marine and Land-Based),” final rule, 67 FR 68241, November 8, 2002.

• “Control of Emissions of Air Pollution from Nonroad Diesel Engines and Fuel.” final rule, April 2004.

Also contributing to projected emission reductions are the following federal/state onroad mobile

source control measures:

• Reformulated gasoline in Hillsborough, Merrimack, R ockingham, and Strafford Counties;

• An enhanced safety inspection program, including a vehicle anti-tampering inspection for vehicles less than 20 years old;New Hampshire Ozone Maintenance SIP Page 12

• On-board diagnostics testing for 1996 and newer veh icles in lieu of the anti-tampering inspection;

• Participation in the National Low Emission Vehicle (Northeast) program;

• The Federal Tier II vehicle standards and reduced g asoline sulfur limits.

Regarding stationary sources, it should be noted th at two relatively large VOC-emitting sources (Batesville Manufacturing, Inc. and Venture Holding s) have closed since the time of the 2002 inventory. However, because NHDES has retained the emission reduction credits from these facility closures for possible future use, these emissions h ave been retained in the 2012 and 2014 inventories.

The inventory data clearly demonstrate that total e missions of ozone precursors within the fivecounty region are projected to decline between 2002 and 2014, indicating continued attainment of the 1997 8-hour ozone standard in the maintenance p lanning area. All of the technical data files associated with the 2002 attainment inventory and t he 2012 and 2014 projected inventories are

enclosed on CD-ROM as Attachment A.

Section 110 of the Clean Air Act requires individua l states to prevent air pollution emissions that would cause nonattainment of the NAAQS in downwind states. As NHDES has previously observed, over 92 percent of air pollution is trans ported into the state from other areas during periods of poor air quality. 3 Through active participation in the Ozone Transpo rt Commission (OTC), the Northeast States for Coordinated Air Use Management (NESCAUM), and other regional organizations, NHDES has cooperated extens ively with upwind states and EPA to reduce

emissions and achieve attainment of the 8-hour ozon e standard. While New Hampshire’s continued attainment of this standard will depend on the succ ess of in-state control measures, future attainment will depend to an even greater degree on the efficacy of super-regional control measures that reduce ozone and ozone-precursor transport int o New Hampshire.

3 New Hampshire Department of Environmental Services , “Air Pollution Transport and How It Affects New H ampshire,” May 2004.New Hampshire Ozone Maintenance SIP Page 13

3. AMBIENT AIR QUALITY MONITORING

The maintenance plan for the 1997 8-hour ozone stan dard must include provisions for the operation of an ambient air quality modeling network to verif y continued maintenance of the 8-hour ozone standard in the planning area. NHDES has monitorin g stations throughout the state that record criteria pollutant levels and other air quality dat a. Table 3-1 presents 8-hour ozone monitoring data for the most recent three-year period from monitors in the five southernmost counties of Cheshire, Hillsborough, Merrimack, Rockingham, and Strafford. The 2010-2011 design values and 2012 threshold values provide further indication that th e maintenance area is likely to continue meeting

the 1997 8-hour ozone standard for the duration of the planning period. Based on quality-assured data through for the 2011 ozone season, the most re cent design values were in the low- to mid-60’s parts per billion (ppb) range for most sites, and n one was higher than 70 ppb.

Table 3-1. 8-Hour Ozone Monitoring Data: 2012 Thre shold Values and 2010-2011 Design

Values Based on Fourth-Highest Annual Maxima (ppb)

4 th Highest Value Design Value * Most Recent Year at

or above Threshold Monitor

Location AQS

Number 2008 2009 2010 2011 2010 2011 2012

Threshold

Value ** 1 st

Highest 4 th

Highest

Keene 330050007 68 62 64 62 64 62 129 None None

Peterborough 330115001 76 72 77 62 75 70 116 None N one

Nashua 330111011 67 66 67 65 66 66 123 None None

Manchester 330110020 64 60 63 *** 62 *** *** None None

Concord 330131007 67 64 68 64 66 65 123 None None

Portsmouth 330150014 69 70 66 64 68 66 125 1988 Non e Rye 330150016 75 68 66 66 69 66 123 1991 None

* Example: The 2010 design value is the 3-year average of the annual fourth-highest 8-h our ozone concentration for the period

2008-2010.

** The 2012 threshold value is the fourth-highest m onitored daily maximum 8-hour ozone value during th e 2012 ozone season that would cause the 2012 design value to exceed th e 1997 8-hour ozone NAAQS.

*** No data; monitor was moved to Londonderry in 20 11.

New Hampshire is committed to the continuing operat ion of an effective air quality monitoring network to verify the area's attainment status in a ccordance with 40 CFR Part 58, to the extent that federal funding assistance remains sufficient for t his purpose. New Hampshire proposes no modifications to the existing monitoring network at this time. Any future proposal to modify the monitoring network will be accompanied by supportin g technical and statistical analyses as necessary. Final monitoring network design shall b e subject to the approval of the EPA Regional

Administrator.New Hampshire Ozone Maintenance SIP Page 14

4. CONTINGENCY PLAN

As established at 40 CFR 51.905(a)(3)(iii) and (4)( ii)), the maintenance plan must include contingency provisions to correct any NAAQS violati on that occurs after redesignation of an area. EPA guidance 4 on this subject calls for contingency measures in the SIP, along with a schedule and procedure for adoption and implementation, that can be implemented in a timely fashion once they are triggered. The schedule should be as expeditio us as practicable, but no longer than 24 months. The state should also identify specific indicators, or triggers, for setting the contingency plan into action. Possible triggers would be a monitored exc eedance of the 8-hour ozone standard or an exceedance of a precursor emission level on which m aintenance is based.

Despite New Hampshire’s best efforts to maintain co mpliance with air quality standards, the possibility exists that ambient ozone concentration s might at some future date exceed the NAAQS. Therefore, in accordance with the requirements of S ection 175A(d), New Hampshire has identified various contingency measures that could be taken fo llowing an ozone “trigger” event and is committed to pursuing the following protocol:

1. At the conclusion of each ozone season, NHDES will evaluate whether the 8-hour ozone design value for any ozone monitor in the planning area is above or below the 1997 8-hour ozone standard (the “trigger”). The design value, in the case of this standard, is defined as the average of the annual 4 th highest daily maximum 8-hour average concentration for the preceding 3-year period.

2. If the design value is above the standard for any o zone monitor, NHDES will investigate the

cause and determine whether the exceedance is due t o:

a. an increase in emissions from local, in-state sourc es; b. an increase in emissions from upwind, out-of-state sources; or

c. exceptional event as defined in 40 CFR 50.1.

3. If an increase in in-state emissions is determined to be a contributing factor to the exceedance, NHDES will evaluate the projected in-state emission s for the next ozone season. If the projected in-state emissions are not expected to de crease enough in the next ozone season to mitigate the violation, New Hampshire will implemen t one or more of the contingency

measures listed below or will substitute other VOC or NOx control measures as necessary to

achieve additional in-state emission reductions.

4. The contingency measures(s) will be selected by the Governor or the Governor’s designee

within six months of the end of the ozone season fo r which contingency measures have been determined to be needed. New Hampshire will then i nitiate a course of action to implement enforceable control measure(s) to rectify the probl em. New rulemaking can typically be adopted and implemented within a 12-month timeframe . NHDES will update the maintenance plan as necessary and develop and imple ment required regulations as soon as practicable within the guidelines established in th e New Hampshire Administrative Procedures Act, but no later than 18 months after selection of the appropriate measure.

New Hampshire is studying an array of possible cont ingency measures that would achieve further reductions in NOx and VOC emissions, including the following emission controls previously proposed by the Northeast states:

4 See reference in footnote 1.New Hampshire Ozone Maintenance SIP Page 15

• NOx controls for industrial, commercial, and institutional (ICI) boi lers;

• VOC controls for emulsified and cutback asphalt paving ; and

• VOC controls for consumer products

.

These contingency measures are among several OTC co ntrol measures 5 exceeding current on-thebooks/on-the-way (OTB/OTW) emission controls and se rving as a subset of potential additional

controls measures called beyond-on-the-way (BOTW). Details on BOTW control measures may be found in MACTEC’s report “Development of Emission P rojections for 2009, 2012 and 2018 for NonEGU Point, Area and Nonroad Source in the MANE-V U Region,” Final Report, February 2007. Estimated emission reductions for New Hampsh ire from the three named control measures are given in Table 4-1.

Table 4-1. Estimated Emission Reductions from Thre e BOTW Control Measures

Control Measure Pollutant 2009 Estimated Emission Reductions (tons per day)

ICI Boilers (OTC 2006 Model Rule) NOx 1.9

Emulsified Asphalt Paving (OTC guidelines) VOC 4.4

Consumer Products (OTC 2006 Model Rule) VOC 0.3

Source: MACTEC, 2007

These potential contingency measures are further de scribed in subparts 4.1 through 4.3, below.

4.1 ICI Boilers (at Major Point Sources)

In 2006, the OTC commissioners recommended that the OTC member states pursue “as necessary and appropriate” state-specific rulemakings to establish required em ission reduction percentages, emission rate performance standards, or control tec hnologies to reduce emissions from industrial, commercial, and institutional boilers (OTC Resoluti on 06-02). The approximately 2-ton-per-day reduction in NOx emissions from ICI boilers reporte d in Table 4-1 was based on implementation of

OTC’s recommended control levels on boilers of 25-2 50 MMBtu/hr heat input capacity at major point sources in New Hampshire.

4.2 Emulsified Asphalt Paving

NHDES is currently evaluating the proposed continge ncy measure for emulsified asphalt paving. OTC’s guideline would limit the VOC content of emul sified asphalt to 2 percent or less. The VOC content of emulsified asphalt in New Hampshire is a ssumed to be 2.5 percent at present. Thus, the

estimated VOC emission reduction from this source c ategory would be approximately 20 percent during the ozone season.

4.3 Consumer Products

The contingency measure for consumer products inclu ded in Table 4-1 would replace the OTC 2001 VOC model rules with the OTC 2006 model rules, which provide amendments (adopted by

5 MACTEC Federal Programs, “Identification and Evalu ation of Candidate Control Measures,” Final Technic al Support Document, Ozone Transport Commission, February 28, 2007.New Hampshire Ozone Maintenance SIP Page 16

the California Air Resources Board (CARB) in July 2 005. The amendments revise the existing

VOC limit for contact adhesives and create VOC limi ts for nine new source categories (adhesive removers, electrical cleaner, electronic cleaner, f abric refresher, footwear or leather care, graffiti remover, hairstyling products, toilet care, and woo d cleaner). Based on estimates developed by CARB for 2009, these amendments would reduce VOC em issions by about 2 percent.

4.4 Additional Controls on Boilers

New Hampshire and the other OTC states have continu ed to investigate the possibility of additional controls on ICI boilers and utility boilers as stat ionary sources with the highest potential for NOx

emission reductions. The additional controls would cover a wider range of boilers and would be more stringent than those described in the MACTEC r eport for non-EGU point sources and area sources in New Hampshire. More specifically, recen t OTC proposals being considered by NHDES would provide additional NOx controls on the follow ing boiler categories:

• Oil- and gas-fired boilers serving EGUs (OTC 2010 M odel Rule) : This proposed rule would impose the following NOx emission limitations on oi l- and gas-fired utility boilers with a nameplate capacity of 25 MW or greater: for gas onl y, 0.08 lb/MMBtu; for oil or oil/gas,

0.15 lb/MMBtu.

• New small natural-gas-fired boilers and water heate rs (OTC 2010 Model Rule) : This proposed rule would establish NOx emission standard s for various devices ranging in size from 75,000 to 5,000,000 Btu/hr.

• ICI boilers : Stricter NOx emission standards would be extende d to any ICI boiler above a certain size threshold, e.g., 25 MMBtu/hr.

Since 2006, OTC and the Lake Michigan Air Directors Consortium (LADCO) have worked collaboratively to assess the technical and economi c feasibility of enhanced emission controls on

ICI boilers of all sizes. 6 A NESCAUM study 7 from the same time period examined a variety of technologies available to reduce NOx emissions from ICI boilers with heat input ratings from as low as 10 MMBtu/hr to as high as 1,000 MMBtu/hr. I t was determined that emission reductions of 5 to 90 percent are achievable, depending on boiler size, fuel type, and chosen technology. Generally, the higher control efficiencies are appl icable to larger ICI boilers, of which New Hampshire has relatively few.

NHDES is gathering data on New Hampshire’s current stock of ICI boilers by size, fuel type, and existing control level. Preliminary data indicate that approximately 80 percent of ICI boilers in the state have heat input ratings less than 25 MMBtu/hr and lack NOx controls. Another 13 percent have heat input ratings less than 50 MMBtu/hr and l ack NOx controls. These units – most of them burning fuel oil – account for more than half of al l NOx emissions from ICI boilers in the state. Boilers with heat input ratings above 100 MMBtu/hr, while far fewer in number, would generally have some existing level of NOx controls. Given al l of these facts, NHDES anticipates that any reasonable control program for ICI boilers in New H ampshire would be capable of reducing overall NOx emissions from this sector by 25 percent or mor e.

6 OTC and LADCO, “Evaluation of Control Options for I ndustrial, Commercial and Institutional (ICI) Boile rs,” Technical Support Document, Final, May 14, 2010.

7 NESCAUM, Applicability and Feasibility of NOx, SO 2 , and PM Emission Control Technologies for Industri al, Commercial, and Institutional (ICI) Boilers , November 2008.New Hampshire Ozone Maintenance SIP Page 17

Ongoing state and regional initiatives to control b oiler emissions are overlain by EPA’s proposed or final rules pertaining to National Emission Standar ds for Hazardous Air Pollutants (NESHAP) for industrial, commercial, and institutional (ICI) boi lers at major sources and area sources; NESHAP for coal- and oil-fired electrical generating units ; and New Source Performance Standards (NSPS) for fossil-fuel-fired electric utility and ICI boil ers. Under these rules, affected sources would be subject to mandatory new emission limits and/or per iodic boiler tune-ups that would yield direct

emission reductions or indirect co-benefits with re spect to NOx and VOC control.

4.5 Other Contingency Measures

NHDES is evaluating other potential NOx and VOC con trol measures that could be applied, if necessary, to further reduce ozone levels in the ma intenance area. These control measures are listed in Table 4-2 along with the previously mentioned co ntingency measures for boilers, asphalt paving, and consumer products.

Table 4-2. Potential Contingency Measures for Redu cing Ozone Levels

Control Measure Source Category

NOx Control Measures

Oil and Gas Boilers Serving EGUs (OTC 2010 Model Ru le) Major Point

New Small Natural-Gas-Fired Boilers and Water Heaters (OTC 2010 Model Rule) Area*

ICI Boilers Area or Major Point

Stationary Generators (OTC 2010 Model Rule) Area

Motor Vehicle Anti-Idling (mandatory, not voluntary) Onroad Mobile

California Low-Emission Vehicles (CALEV) Standards Onroad Mobile

Low-Carbon Fuel Standard (regional) Onroad Mobile / Nonroad

VOC Control Measures

Large above-Ground Storage Tanks (OTC 2010 Model Ru le) Major Point

Emulsified and Cutback Asphalt Paving (OTC guidelin es) Area

Adhesives and Sealants Application (OTC 2006 Model Rule) Area

Architectural and Industrial Maintenance Coatings (OT C 2009 Model Rule) Area

Solvent Cleaning (OTC 2009 Model Rule) Area

Consumer Products (OTC 2006 Model Rule) Area

Consumer Products (OTC 2010 Model Rule) Area

Motor Vehicle and Mobile Equipment Non-Assembly Line Coatings Operations (OTC 2009 Model Rule) Area

Stage II Vapor Recovery** Area

*Area sources include minor emission sources, typic ally large in number and widely distributed. ** Stage II Vapor Recovery would serve as a conting ency measure upon determination of widespread use o f ORVR.New Hampshire Ozone Maintenance SIP Page 18

5. VERIFICATION OF CONTINUED ATTAINMENT

EPA guidance calls upon the state to show how it wi ll track the progress of the maintenance plan, i.e., demonstrate that compliance with the 8-hour o zone standard is being maintained during the 10- year planning period. Tracking is necessary becaus e the emission projections that form the basis of the maintenance demonstration depend on assumptions of point and area source growth and implementation of specific emission control measure s. One option for tracking maintenance is to make periodic updates to the emissions inventory pr ojections. Such an update could be based, in part, on the annual update of EPA’s national emissi ons inventory (NEI) database and could indicate new source growth and other changes from the attain ment inventory (such as changes in vehicle miles traveled or in traffic patterns).

New Hampshire will track the maintenance of attainm ent by analyzing air quality trends at local monitors and annually updating the state’s emission s inventories. NHDES routinely reviews air quality monitoring data and keeps charts showing tr ends in air quality at individual monitor sites. As required by law, New Hampshire produces comprehe nsive emissions inventories on a three-year cycle. The latest one, the 2008 inventory, will be completed this year, to be followed by formal inventories for 2011 and 2014. For the off-years, New Hampshire revises the inventories annually using updated emissions data for the largest source s.

6. ADMINISTRATIVE DOCUMENTS

In accordance with the requirements for SIP submiss ions established in 40 CFR 51.103, the following documentation is herewith provided as integral to t his maintenance plan:

• A formal letter of submittal from the Governor or h is designee, requesting EPA approval of this SIP revision;

• Evidence that the NHDES has the necessary legal aut hority under state law to adopt and implement the plan.

• Evidence that public notice was given of the propos ed change consistent with procedures approved by EPA, including the date of publication of such notice.

• Certification that public hearing(s) were held in a ccordance with the information provided in the public notice and the state's laws and constitu tion, if applicable and consistent with the public hearing requirements in 40 CFR 51.102.

• Compilation of public comments and the state's resp onse thereto.

Documentation of legal authority, public notice, ce rtification of the public process, and public comments and responses are provided in Attachment B

.

7. SUMMARY

The State of New Hampshire is committed to achievin g and maintaining air quality standards for ground-level ozone and its chemical precursors. Th e entire maintenance planning area is currently in attainment of the 1997 8-hour ozone NAAQS of 0.0 8 parts per million and is projected to stay in attainment for the duration of the 10-year planning period that ends on June 15, 2014.New Hampshire Ozone Maintenance SIP Page 19

With this SIP revision, New Hampshire has met all S ection 110(a)(1) maintenance plan requirements. The maintenance plan provides for co ntinued compliance with the 8-hour ozone NAAQS in all areas that were classified as nonattai nment areas for the former 1-hour ozone standard, as evidenced by the following plan elemen ts:

1. Attainment Inventory . New Hampshire compiled and used a 2002 baseline inventory of

NOx and VOC emissions in accordance with EPA’s Cons olidated Emissions Reporting Rule.

2. Maintenance Demonstration . New Hampshire prepared 2012 and 2014 projected i nventories of NOx and VOC emissions for comparison with the 20 02 baseline inventory. These

inventories indicate a sustained downward trend in NOx and VOC emissions within the maintenance planning area, demonstrating that the 1 997 8-hour ozone standard will be maintained through at least 2014. The downward tre nd in NOx and VOC emissions is reinforced by ozone monitoring data, which show a s imilar, steady downward trend. (Note: New Hampshire recently prepared a 2008 Periodic Emi ssions Inventory as required by the Clean Air Act. This inventory has been submitted e lectronically to EPA for inclusion in the 2008 National Emissions Inventory. It is also bein g submitted to EPA for SIP approval along with New Hampshire's redesignation request fo r the 1997 8-hour ozone nonattainment area. The 2008 inventory, although not directly re lated to the maintenance plan, is

consistent with the stated trend in NOx and VOC emi ssions.)

3. Ambient Air Quality Monitoring . New Hampshire is committed to the continued oper ation of an effective air quality monitoring network to v erify maintenance of the planning area’s

attainment status.

4. Contingency Plan . New Hampshire has developed a contingency plan t o ensure that any violations of the 8-hour ozone NAAQS, should they o ccur, are addressed and promptly

corrected.

5. Verification of Continued Attainment . New Hampshire is committed to tracking the maintenance of attainment at least annually – a fre quency that would enable the implementation of contingency measures within a sho rt timeframe, should such measures become necessary. Verification will be based on an alysis of air quality trends and changes

in emissions inventories.New Hampshire Ozone Maintenance SIP Page 20

This page intentionally left blank.ATTACHMENT A

2002 Attainment Inventory and 2012 and 2014 Projected Inventories

(Files available on accompanying CD.)This page intentionally left blank.ATTACHMENT B

Administrative Documents:

 Evidence of Legal Authority

 Certification of Public Process

 Copy of Public Notice

 Public Comments and State’s ResponseThis page intentionally left blank.This page intentionally left blank.This page intentionally left blank.This page intentionally left blank.STATE OF NEW HAMPSHIRE DEPARTMENT OF ENVIRONMENTAL SERVICES AIR RESOURCES

DIVISION CONCORD, NEW HAMPSHIRE NOTICE OF PUBLIC CO MMENT PERIOD AND PUBLIC HEARINGS In accordance with New Hampshire Administr ative Rule Env-A 204.01(b) and Title 40 of the Code of Federal Regulations (CFR) Section 51.102, notice is hereby given that the New Hampshire Department of Environmental Services, Air Resources Division (the Department) has prepared, and intends to submit to the U.S. Environmental Protection Agency (EPA) for approval, a request for redesignation of the Boston-Manchester-Portsmouth (SE), New Hampshire 8-hour ozone (1997 standard) nonattai nment area, including a maintenance plan for that area, hereinafter referred to as "Req uest for Redesignation (including MP I)," pursuant to section 110(a) of the federal Clean Air Act. This request, if approved by EPA, will revise New Hampshire's State Implementation Plan (S IP). In addition, the Department has prepared and intends to submit to EPA for approval as a SIP revision a maintenance plan, hereinafter referred to as "MP II," for the area of the state that was formerly designated nonattainment for the 1-hour ozone standard, but wh ich was classified as unclassifiable/attainment for the 8-hour ozone stan dard. The Boston-Manchester-Portsmouth (SE), New Hampshire 8-hour ozone (1997 standard) no nattainment area consists of 52 cities and towns in the southern and/or eastern parts of H illsborough, Merrimack, Rockingham, and Strafford Counties. Ground-level ozone monitoring d ata for the most recent 3-year monitoring period of 2008-2010 show that air quality in the no nattainment area has met the 1997 National Ambient Air Quality Standard for 8-hour oz one. For EPA to approve the Request for Redesignation, the Department must submit maintenan ce plan MP I as part of this request, detailing how the state will insure that the area w ill not fall back into nonattainment once it is redesignated as attainment. MP I must demonstrate t hat the area will remain in compliance for a period of 10 years from the date of redesignation . The former nonattainment area for the 1-

hour ozone standard that was classified as unclassi fiable/attainment for the 8-hour ozone standard on June 15, 2004, consists of 79 cities an d towns in Cheshire County and the northern and/or western parts of Hillsborough, Merr imack, Rockingham, and Strafford Counties. The maintenance plan for this area, MP II , must demonstrate that the area will remain in compliance with the 8-hour ozone standard for the 10-year period from June 15, 2004 to June 15, 2014. The Department hereby solici ts comments and has scheduled public hearings on the Request for Redesignation (includin g MP I) and MP II. A public hearing on the Request for Redesignation (including MP I) has been scheduled for 10:30 a.m., Tuesday, January 24, 2012, at the Department offices in Room s 110 and 111 at 29 Hazen Drive, Concord, NH 03301. A public hearing on MP II has be en scheduled to start at the conclusion of the first hearing. Comments may be presented orally and/or in writing at the public hearings. Written comments may also be submitted by postal de livery, email, or fax to Charles Martone, Air Resources Division, NH Department of Environmen tal Services, P.O. Box 95, Concord, NH 03302-0095; email Charles.Martone@des.nh.gov; fax ( 603)271-1381. Please specify which plan each comment addresses. All written comments o n the Request for Redesignation (including MP I) and all written comments on MP II must be received by 4:00 p.m. on Tuesday, January 24, 2012, to be entered into the record. Th e Request for Redesignation (including MP I) and MP II are available for public inspection at the Department's offices at 29 Hazen Drive, Concord, NH, during regular working hours from 8:00 a.m. to 4:00 p.m., Monday through Friday. The main text of both documents may be down loaded from the Department's website

at http://des.nh.gov/ . Questions regarding the Request for Redesignation (including MP I) and MP II may be directed to Charles Martone at (603) 2 71- 1089. Robert R. Scott Director, Air Resources Division NH Department of Environmental S ervices Dated: December 23, 2011

Appeared in: The Union Leader on Friday, 12/23/2011This page intentionally left blank.Page 1 of 5



### Responses to Comments on New Hampshire's Proposed Maintenance Plan for

Former 1-Hour Ozone Nonattainment Areas in Cheshire , Hillsborough,

Merrimack, Rockingham, and Strafford Counties

On January 24, 2012, the New Hampshire Department o f Environmental Services (NHDES)

received comments from the U.S. Environmental Prote ction Agency (EPA) on New Hampshire’s proposed Section 110(a)(1) maintenance plan for for mer 1-hour ozone nonattainment areas in Cheshire, Hillsborough, Merrimack, Rockingham, and Strafford Counties. No other comments were received. The following are NHDES’s responses to EPA’s comments. Comments are written in regular font and responses are written in italics

.

1. On page 6, the citation “(40 FR 72574)” should b e “(67 FR 72574).”

Response: The citation has been corrected.

2. On page 6, the citation “(40 FR 59338)” should b e “(70 FR 59338).”

Response: As above.

Ozone Data

3. On page 12, Table 3-1 should identify that the o zone concentrations are presented in units of parts per billion (ppb).

Response: The requested clarification has been added.

4. On page 12, in Table 3-1, the 2012 threshold val ues should be as follows:

Keene 129 ppb Peterborough 116 ppb Nashua 123 ppb Concord 123 ppb Portsmouth 125 ppb Rye 123 ppb

Therefore, NH DES should adjust the “most recent ye ar at or above the threshold” column correspondingly. In addition, it should be noted t hat in the current version of the table, it appears that 1-hour values, rather than 8-hour values, were used when determining the most recent year at or

above the threshold.

Response: The 2012 threshold values and the most recent years at or above threshold have been

corrected in the table.Page 2 of 5

Motor Vehicle Emission Estimates

5. The CD files submitted to EPA for review only in cluded the MOVES2010 input and output files associated with the redesignation request. The fin al submittal of the Section 110(a)(1) maintenance plan should also include the MOVES2010 files associ ated with this plan.

Response: Preliminary MOVES input/output files for the main tenance plan were mailed on a CDROM to Ariel Garcia, EPA, as requested in a phone c all to Felice Janelle, NHDES. A complete data CD-ROM, including MOVES input/output files and supporting files for the 2002, 2012, and 2014 emissions inventories, is being provided in as sociation with this Section 110(a)(1) maintenance plan submittal.

2002 Inventory and Projections to 2012 and 2014

6. Page 11 of the proposed maintenance plan for att ainment areas in the 5-county, former 1-hour ozone nonattainment areas indicates that,

“There has been a decline in actual point source VO C emissions since 2002, which is partially attributable to the closure of two relati vely large VOC-emitting sources (Batesville Manufacturing, Inc., and Venture Holdings). Howeve r, because NHDES has retained the emission reduction credits from these facility clos ures for possible future use, these emission

reductions are not included in the 2012 and 2014 in ventories.”

EPA suggests that NH DES clarify that although thes e facilities have been closed, their emissions

have been retained in the 2012 and 2014 inventories

.

Response: The emissions reductions from the closings of Bat esville Manufacturing and Venture Holdings were retained in the 2012 and 2014 invento ries. The relevant wording in Section 2.3 of the maintenance plan has been revised to clarify th is fact.

7. New Hampshire selected its 2002 emissions invent ory to use as the base year inventory for the maintenance plan developed to support redesignation of former l -hour nonattainment areas in the state. The 2002 inventory was submitted to EPA on June 7, 2007. New Hampshire's final maintenance plan submittal for this area should inc lude a reference to the 2002 inventory submittal, as EPA will need to approve the 2002 inventory into the SIP.

Response: The second paragraph of Section 2.1 of the mainte nance plan has been revised to provide specific reference to the 2002 emissions in ventory previously submitted to EPA.

8. It is evident that New Hampshire intends to use full county inventories for the maintenance plan for the 5 county former 1-hour nonattainment areas. This should be clearly stated in the final maintenance plan submittal, particularly since the maintenance plan developed for New Hampshire’s 8-hour nonattainment area was not prepa red using full counties, but rather, is based on the town by town geography of that area.

Response: Full county inventories were used as a reasonable proxy for the irregularly-shaped geographic region that comprises the planning area for the maintenance plan. Wording in Section 2 of the maintenance plan has been edited to explai n and clarify this fact.Page 3 of 5

9. The inventory estimates contained in the 2002 in ventory are summarized in several different geographic arrangements. The closest summary that corresponds to the 5-county area that is the subject of this maintenance plan is the summary for the “1-hour 4-county area”. The four counties included in this summation are Hillsborough, Merrim ack, Rockingham, and Strafford. By adding in emissions for Cheshire County, the inventory for th e 5-county area that is the subject of the onehour redesignation request can be obtained. Table 1 below illustrates this exercise for VOC emissions using the 2002 emissions inventory, and t hen compares that sum to the emission estimates shown within Table 2-1 of the state's pro posed maintenance plan for this area. Table 2 illustrates this comparison for NOx emissions.

The reasons for the differences in the 5 county tot al emission estimates should be identified and

corrected.

Response: The reasons for the differences in the 5 county t otal emissions between the 2002 inventory and the proposed maintenance plan are as follows:

• The on-road mobile emissions estimates for the main tenance plan were calculated with MOVES, which was not available at the time that the 2002 Periodic Emissions Inventory was prepared. On-road mobile emissions estimates f or the 2002 Periodic Emissions Inventory were calculated using MOBILE6.2 emission factors.

• Similarly, Stage II vehicle refueling emissions est imates (SCC 25-01-060-100) for the maintenance plan were calculated with MOVES and wer e included and reported in the on-road mobile category. Stage II emissions estima tes for the 2002 Periodic Emissions Inventory were calculated using MOBILE6.2 emission factors, and they were reported in the area source category. Since this category is n ow calculated with MOVES and included under on-road mobile, the MOBILE6.2-based stage II refueling emissions estimates were removed from the area source invento ry. This resulted in an adjustment to the 2002 maintenance plan area source inventory of -2,638 pounds per day of VOC when compared with the previously submitted 2002 Pe riodic Emissions Inventory.Page 4 of 5

• In compiling the 2002 figures for the maintenance p lan, it was discovered that emissions estimates for the industrial wood combustion catego ry (SCC 21-02-008-000) should not have been calculated and reported under the area so urce category. All industrial wood combustion in 2002 would have occurred at permitted point source facilities, and making an area source estimate for this category ca used double-counting. Therefore, the area source estimate for industrial wood combus tion was removed. This resulted in a correction to the 2002 maintenance plan area sour ce inventory of -25,357 and -880 pounds per day of NOx and VOC respectively when com pared with the previously submitted 2002 Periodic Emissions Inventory.

This explanation has been added to Section 2.3 of t he maintenance plan.

10. Section 2.2 of the proposed maintenance plan fo r the 5-county attainment area mentions that growth factors from the Economic Growth and Analysi s System (EGAS) were used to project point

and area source emissions to 2012 and 2014. The fi nal submittal should include the specific point and area source growth factors that were used to ma ke these projections.

Response: All of the supporting technical files for the pro jected 2012 and 2014 emissions inventories relevant to the Section 110(a)(1) maint enance plan are being provided to EPA on CDROM. These files include the EGAS factors that wer e used to do the projections. Because final, quality-assured emissions data for calendar year 20 11 are not yet available, NHDES used 2010 actual emissions data and the applicable growth fac tors to develop revised point source emissions estimates for the 2012 and 2014 inventories. Table 2-1 of the maintenance plan has been revised accordingly.

Contingency Measures

11. On page 13 in Section 4, NH DES cites one reaso n to investigate an ozone season exceedance as “an anomaly in the ozone-season meteorology”. Sinc e weather anomalies alone do not exempt NH DES from contingency measures, EPA recommends repla cing this bullet with reference to “exceptional events,” as shown below:

“2. If the design value is above the standard/or an y ozone monitor, NHDES will investigate

the cause and determine whether the exceedance is d ue to: • an increase in emissions from local, in-state sou rces; • an increase in emissions from upwind, out-of-stat e sources; or • an anomaly in the ozone season meteorology an exceptional event as defined in

40 CFR 50.1. ”

Response: The requested rewording has been made.

12. On page 13, EPA recommends that NH DES delete t he word "significant" from the third step for the protocol, as shown below, since all factors con tributing to ozone exceedances should be evaluated:

“3. If an increase in in-state emissions is determ ined to be a significant contributing factor to the exceedance, NHDES will evaluate the projecte d in-state emissions for the next ozone

season.”

Response: The word “significant” has been removed.Page 5 of 5

13. On page 13, the 4th step of the protocol states :

"The contingency measures(s) will be selected by th e Governor or the Governor's designee

within six months of the end of the ozone season fo r which contingency measures have been determined to be needed. New Hampshire will then i nitiate a course of action to implement enforceable control measures) to rectify the proble m. New rulemaking, when required, can typically be adopted and implemented within a 12-mo nth timeframe, assuming that no new legislation is required.”

In the final submittal, NH DES should clarify the t imeframe to implement contingency measures.

Response: The end of the quoted paragraph has been revised to read as follows: “New rulemaking can typically be adopted and implemented within a 1 2-month timeframe. NHDES will update the maintenance plan as necessary and develop and imple ment required regulations as soon as practicable within the guidelines established in th e New Hampshire Administrative Procedures Act, but no later than 18 months after selection of the appropriate measure.”

14. The following sentence from page 18 of the sect ion 110(a) maintenance plan should either be corrected, or clarified:

“Note: New Hampshire previously prepared and submit ted to EPA a 2008 periodic emissions inventory as required by the Clean Air Ac t.”

It is not clear whether New Hampshire is referencin g a periodic emissions inventory submittal and accompanying text write-up, such as the submittal N ew Hampshire made to EPA on June 7, 2007, of a 2002 periodic inventory, or whether this sente nce is referring to New Hampshire's electronic

data submittal to the EPA's national emissions inve ntory database of emission estimates for calendar year 2008.

Response: New Hampshire was referencing the 2008 emissions inventory in a broad sense, as information that corroborates the observed downward trend in emissions. The broader 2008 emissions inventory includes the electronic data su bmittal that New Hampshire made to EPA for inclusion in the 2008 National Emissions Inventory as well as the 2008 inventory SIP submittal that New Hampshire is making in conjunction with the 8-h our ozone redesignation request. The sentence in question has been revised accordingly.